Climate Change (Scotland) Bill – Call for Views

In summary, ACE welcomes the Scottish Government’s ambition in introducing a Climate Change Bill which sets statutory targets for reductions in greenhouse gas emissions and which supports the delivery of those targets. We also welcome the overall target of an 80% reduction in emissions by 2050 on 1990 levels, which is broadly in line with the current scientific consensus, and we welcome the fact that the Bill will cover all six Kyoto gases.

However, we believe some crucial details about how these emissions cuts will be achieved are missing – in particular the lack of sectoral targets on the face of the Bill is a major failing. In addition, the section of the Bill focussed on energy efficiency (Part 5, Chapter 3) falls far short of what is needed to achieve the emissions reductions envisioned in earlier sections of the Bill. The Bill must be strengthened if it is to deliver a fair and equitable reduction in Scotland’s emissions and give business and industry the certainty we need to invest for emissions cuts.

There are in our view a number of conspicuous shortcomings in the proposals that will hamper the Bill’s effectiveness. Principle among these is the lack of any limit on the number of carbon credits that can be purchased from abroad. The Scottish Government should be aiming for 100 percent internal provision to achieve the Scottish target. This would allow the Scottish economy to benefit from early action to reduce emissions, and, if investment is suitably targeted, would also help to achieve existing Scottish Government targets on fuel poverty.

ACE believes strongly in the effectiveness of statutory targets, with a variety of incentives and sanctions including the option of affordable legal challenge. Statutory targets will not only give direction to Government, but are vital to give business the certainty it needs to make the appropriate investment decisions. For building materials (including energy efficiency materials), the investment required to increase production is immense, and local workforces must be trained up and retained. This is not a business where imports can be relied upon to make good a shortfall in domestic production – imports are more expensive because of the bulky nature of the materials. For this reason and several others, ACE supports sectoral targets, as set out below.

While the proposal for annual emissions reduction targets is welcome, it is disappointing that these annual targets are not set in statute from the start. A cycle of annual reports to Parliament on progress towards meeting the annual targets, ideally given by the First Minister, would help to deliver the required level of accountability.

Finally, it is essential that all greenhouse gas emissions, including those from aviation and shipping, are included in the Bill.